ML043070614

License Amendment Request: Revision to Technical Specification Section 5.0, Design Features

ML043070614
Person / Time
Site:	Nine Mile Point
Issue date:	10/22/2004
From:	Spina J Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L 1875
Download: ML043070614 (12)

Text

I-Constellation Energy*

RO. Box 63 Nine Mile Point Nuclear Station Lycoming, New York 13093 October 22, 2004 NMP1L 1875 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Nine Mile Point Unit 1 Docket No. 50-220 Facility Operating License No. DPR-63 License Amendment Request: Revision to Technical Specification Section 5.0, Design Features Gentlemen:

Pursuant to 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) hereby requests an amendment to Nine Mile Point Unit 1 (NMP1) Operating License DPR-63. The proposed changes revise NMP 1 Technical Specification (TS) Section 5.0, "Design Features." Specifically, the proposed changes relocate design details contained in the following TS sections to the Updated Final Safety Analysis Report (UFSAR), where the information already exists: TS 5.3, "Reactor Vessel;" TS 5.4, "Containment;" and TS 5.6, "Seismic Design." This change supports the License Renewal Application (bRA) that NMPNS submitted to the NRC in a letter dated May 26, 2004, by relocating the reactor vessel design lifetime (currently stated as 40 years) from TS 5.3 to the UFSAR. The proposed TS changes are consistent with the content of the Design Features section (Section 4.0) of the BWR Standard Technical Specifications (NUREG-1433 and NUREG-1434).

NMPNS requests approval of the proposed amendment by September 30, 2005, to support issuance of the safety evaluation report for the LRA with implementation within 90 days of approval. This letter contains no new regulatory commitments.

Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this license amendment request and the associated analyses regarding no significant hazards consideration to the appropriate state representative.

Very truly yours, Ja A. Spina ce President Nine Mile Point JAS/DEV/jm Ao

Page 2 NMP1L 1875 STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, James A. Spina, being duly sworn, state that I am Vice President Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and foethe State of New York and County of Oswego, this Z day of o

ff

,, 2004.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires:

/o/zz/oC, Date Cot Attachments:

1. Evaluation of Proposed Changes

2. Proposed Technical Specification Changes (Mark-up) cc:

Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. G. K; Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR (2 copies)

Mr. N. B. Le, License Renewal Project Manager, NRR Mr. J. P. Spath, NYSERDA

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request: Revision to Technical Specification Section 5. 0, Design Features

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

Page 1 of5

1.0 DESCRIPTION

This letter is a request to amend Nine Mile Point Unit 1 (NWP1)

Operating License DPR-63.

The proposed changes revise NMP I Technical Specification (TS) Section 5.0, "Design Features." Specifically, the proposed changes relocate design details contained in the following TS sections to the Updated Final Safety Analysis Report (UFSAR), where the information already exists: TS 5.3, "Reactor Vessel;" TS 5.4, "Containment;" and TS 5.6, "Seismic Design."

This change supports the License Renewal Application that Nine Mile Point Nuclear Station, LLC (NMPNS) submitted to the NRC in a letter dated May 26, 2004, by relocating the reactor vessel design lifetime (currently stated as 40 years) from TS 5.3 to the UJFSAR.

2.0 PROPOSED CHANGE

TS 5.3, "Reactor Vessel," lists certain design features of the reactor vessel, including the internal height, internal diameter, design lifetime, and materials of construction. The proposed changes relocate this information to UFSAR Section V-B.2.0, "Reactor Vessel," where the information already exists.

TS 5.4, "Containment," describes certain design features and parameters of the containment system, including primary containment volumes, design pressures, design temperature, and material of construction. The proposed changes relocate this information to UFSAR Section VI-B, "Primary Containment - Pressure Suppression System," where the information already exists.

TS 5.4 also describes certain design information for the reactor building, including maximum in-leakage rate and design internal and external loading conditions. The proposed changes relocate this information to UFSAR Section VI-C, "Secondary Containment - Reactor Building," where the information already exists.

TS 5.6, "Seismic Design," describes details regarding the seismic design of the reactor building and engineered safeguards contained therein. The proposed changes relocate this information to UFSAR Sections III, "Buildings and Structures," VI-C, "Secondary Containment - Reactor Building," and XVI-D, "Design of Structures, Components, Equipment, and Systems," where the information already exists.

3.0 BACKGROUND

TS 5.3, 5.4, and 5.6 currently describe design features and parameters that duplicate information that already exists in the UFSAR. In particular, TS 5.3 states that the reactor vessel design lifetime is 40 years, which is consistent with the current operating license expiration date of August 22, 2009. On May 26, 2004, NMPNS submitted a License Renewal Application (LRA) for NMP 1 which seeks to extend the current term of the license by 20 years beyond the current expiration date. Assuming a favorable NRC decision on the LRA, the NMP 1 operating license expiration date would be extended to August 22, 2029. Rather than revise the reactor vessel design lifetime value in TS 5.3 to reflect license renewal, the proposed changes relocate the reactor vessel design lifetime, as well as the other identified design details, from TS Section 5.0 Page 2 of 5

to the UFSAR. Changes to the UFSAR descriptions may then be processed in accordance with the requirements of 10 CFR 50.59. These proposed TS changes are consistent with the content of the Design Features section (Section 4.0) of the BWR Standard Technical Specifications (NUREG-1433, Revision 3 and NUREG-1434, Revision 3).

4.0 TECHNICAL ANALYSIS

The reactor vessel design features and parameters in TS 5.3, the containment system design features and parameters in TS 5.4, and the seismic design details in TS 5.6 are proposed to be relocated to UFSAR Sections III, V-B.2.0, VI-B, VI-C, and XVI-D, where the information already exists. Any changes to these design features and parameters described in the UFSAR must conform to the requirements of 10 CFR 50.59. Furthermore, sufficient detail relating to these design features exists in current TS safety limits, limiting safety system settings, and limiting conditions for operation (LCOs) (e.g., TS 2.2.1, 2.2.2, 3.2.0, 3.3.0, and 3.4.0) to ensure any changes that may affect safety would require prior NRC review and approval. Since the design features with a potential to affect safety are sufficiently addressed by existing TSs, and other design features, if altered or modified in accordance with 10 CFER 50.59, would not result in a significant effect on safety, the criteria of 10 CFR 50.36(c)(4) for inclusion as a Design Feature are not met. Therefore, removing these details from the TS, while maintaining the detail in the UFSAR, will not impact safe operation of the facility. These details are not required to be in the TS to provide adequate protection of the public health and safety.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Siunificant Hazards Consideration Nine Mile Point Nuclear Station, LLC (NMPNS) is proposing to revise the Design Features section of the Nine Mile Point Unit 1 Technical Specifications (TS) by relocating descriptions of certain design details to the Updated Final Safety Analysis Report (UFSAR). The affected TS descriptions pertain to the reactor vessel, containment, and seismic design.

NMPNS has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relocates certain design details from the TS to the UFSAR, where the information already exists. The UFSAR is maintained in accordance with 10 CFR 50.71(e). Any future change to these design details as described in Page 3 of 5

the UFSAR will be evaluated per the requirements of 10 CFR 50.59 to assure that the change does not result in more than a minimal increase in the probability or consequences of an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change will not impose or eliminate any requirements, and adequate control of the information will be maintained in accordance with applicable regulatory requirements.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change has no impact on any safety analysis assumptions. The design details that are being removed from the TS already exist in the UFSAR.

Any future change to these design details as described in the UFSAR will be evaluated per the requirements of 10 CFR 50.59 to assure that the change does not result in a design basis limit for a fission product barrier being exceeded or altered.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above evaluation, NMPNS concludes that the proposed amendment involves no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatorv Requirements/Criteria Based on the considerations discussed above evaluating the proposed change per the requirements of 10 CFR 50.36 and 10 CFR 50.92, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's Page 4 of 5

regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed relocation of design details from the Nine Mile Point Unit 1 Technical Specifications to the Updated Final Safety Analysis Report would not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would not change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 5 of 5

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

The current versions of Technical Specifications pages v, 342, 345, and 346 have been marked-up by hand to reflect the proposed changes.

SECTION 5.0 Design Features 5.1 Site 5.2 Reactor 5.3 5.4 5.5 Storage of Unirradiated and Spent Fuels 5.6 6.0 Administrative Controls 6.1 Responsibility 6.2 Organization 6.3 Unit Staff Qualifications 6.4 Procedures 6.5 Programs and Manuals 6.6 Reporting Requirements 6.7 High Radiation Area DESCRIPTION PAGE 342 342 342 342 345 346 346 347 347 347 349

. 349 350 356 359

• AMENDMENT NO. I4.2, A)845 v

DESIGN FEATURES 5.1 site The Nine Mile Point Nuclear Station and James A. Fitzpatrick Nuclear Power Plant site comprising approximately 1500 acres, is located on the shores of Lake Ontario, about seven miles northeast of Oswego, New York. An exclusion distance of nearly 4000 feet is provided between the Station and the nearest site boundary to the west, a mile to the boundary on the east, and a mile and a half to the southern site boundary (as described in the Sixth Supplement of the FSAR).

Figure 5.1-1 is a Site Boundary Map of Nine Mile Point which allows the identification of gaseous and liquid waste release points. Figure 5.1-1 also defines the unrestricted area within the site boundary that is accessible (except for fenced areas) to member of the public.

5.2 Reactor The reactor core consists of no more than 532 fuel assemblies containing enriched uranium dioxide pellets clad in Zircaloy-2.

The core excess reactivity will be controlled by movable control rods and burnable poisons. The core will be cooled by circulation of water internally and external to the pressure vessel through recirculation loops.

5.3 _ _ _ _ _ _ _ _ _ _ _ _

AMENDMENT NO. 1 3) 342

5.4 Iom I =i o

IvI W14l I The containm t system consi ts of a drywe, suppression c mber and.

actor buildin The pressursuppression s tern consists of drywell with a lume of app ximately 243, 0 cubic feeind an interco ected suppr ssion chamber ith a volume of 209,0 cubic feet. Of his total vof e some 1800, and 120, 0 cubic feet free space available in t drywall and suppr sion chamber, r pectively.

T pertinent desi features no iscussed els ere in the t nical sp ecifi ons are asIows:

////rywell

& Vot Su rssion Chami/

Internal esign Pressure 62

/

35 psig Int a Design Te ature OF 2050 External Desig Pressure 2 psig Sig Material Construction A-2 and A-212 Gr de "B" Firebo teel

/

./

t eto A-300 p~rments./

-/

For long-term st-accident r ovary, the pr ssure suppre on system is d igned to per t flooding to a level least six feet abov the core.

The re tor building is esigned for aximum in-I kage rate of I percent per y at 0.25 inch of ater internal vacu and zero win speed. Exteri loadings for md, snow an ice meet all ap cable codes.

he roof and supp ing structures areesigned to hstand a loadi of 40 psf o now or ice.

e walls and b ding structure re designed to w stand an externa r internal oading of 40 which is ap oximately eq alent to that c sed by a win velocity of 125 h 30 feet above a ground level.

Pressure reli is provided t prevent dam e to the super ucture due to e break of any imary system lin the reactor buil 9.

In this e t, blowout pels will fail, r ving pressure the event of major line ruptur AMENDMENT N3.

4 345

J 5.5 Storage of Unirradiated and Svent Fuel Unirradiated fuel assemblies will normally be stored in critically safe new fuel storage racks in the reactor building storage vault. Even when flooded with water, the resultant keff is less than 0.95. Fresh fuel may also be stored in shipping containers. The unirradiated fuel storage vault is designed and shall be maintained with a storage capacity limited to no more than 200 fuel assemblies.

1066 spent fuel assemblies with up to 15.6 grams (3.0 weight percent) of Uranium-235 per axial centimeters of assembly can be stored in non-poison flux trap racks in the north half of the spent fuel pool. 1710 spent fuel assemblies with up to 18.13 grams (3.75 weight percent) of Uranium-235 per axial centimeters of assembly can be stored in Boraflex racks in the south half of the pool.

These racks have been designed to maintain a keff less than 0.95 under conditions of optimum water moderation. The north and south half of the pool are analyzed to store 1840 and 2246 fuel assemblies, respectively, using racks containing the neutron absorber material Boral. The Boral racks will maintain a keff of less than 0.95 under abnormal and accident conditions. The spent fuel stored i the Boral racks must have a peak lattice enrichment of 4.6 % or less and the k-inf in the standard cold core geometry must be less than or equal to 1.31.

5.6

'The rea or building nd all conta ed engineer safeguards re designeop(for the max um crediblearthquake grd motion w an acce ration of 1 percent of gvity. Dyn c analysis s used to termine the arthquake a eleration, a cable to the rious QeJ ations in t reactor b ing.

AMENDMENT NO.

4Z(

346